Facts:

• Edilberto Esguerra was accused of bigamy for marrying Arsenia Yabut while his first marriage with Sabina Barcelona was still valid.
• The information was filed on January 31, 1952, in the Manila Court of First Instance.
• Esguerra pleaded not guilty and the trial was set for April 24, 1953.
• The trial was postponed multiple times due to various reasons, including the non-appearance of a prosecution witness, the absence of Arsenia Yabut and another vital witness, Esguerra's alleged illness, and the witnesses' deliberate avoidance.
• Frustrated with the delays, Esguerra filed a petition in April 1954, seeking the dismissal of the criminal information against him, citing a violation of his right to a speedy trial.

Issue:

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Ruling:

• Esguerra's petition was denied.
• His right to a speedy t...(Unlock)

Ratio:

• A "speedy trial" means one that can be had as soon as the prosecution can reasonably prepare for it, free from vexatious, capricious, and oppressive delays.
• The right to a speedy trial is relative and depends on the circumstances. It secures the rights of the defendant but does not preclude the rights of public justice.
• The continuances in this case were ordered due to the absence of material witnesses for the prosecution, who were either hiding or being hidden by parties interested in Esguerra's acquittal, possibly with his knowledge or connivance.
• The law would not help Esguerra escape trial if the delays were caused by his actions or those acting on his behalf.
• Defendants cannot be discharged under statutes implementing the right to a speedy trial if they kept the state's witnesses away.
• The continuances were ordered motu proprio by the trial judge.
• Statutes implementing the right to a speedy trial only operate when there is laches on the part of the prosecution, and the accused is not entitled to discharge if the delay is caused by con...continue reading